Post Award: Subrecipient Monitoring

Federal funding agencies require that institutions working on subcontracts under University of Idaho prime awards follow all of the rules and regulations applicable to the prime award. Further, the responsibility for monitoring compliance with those regulations rests with the University as the prime award recipient. Two types of monitoring are required: (1) making sure that the subrecipient institution complies with the auditing requirements of OMB Circular A-133, which is the responsibility of OSP; and (2) making sure that the subrecipient PI at that institution is managing the subaward correctly, which is the responsibility of the UI principal investigator.

In general, the PI is responsible for:

routinely gathering and reviewing any requested technical or progress reports;

routinely reviewing and signing off on all invoices and expenses relative to the proposed budget; and

conducting periodic on-site visits, when necessary.

The University rarely undertakes an audit of a subrecipient. However, if the University PI has reason to question a subrecipient’s expenses, an audit could be the appropriate course of action. More commonly, on-site visits are conducted in connection with ongoing collaborations to manage the research and administrative aspects of the sub-award. Progress reports should be solicited as needed, reviewed, and filed with the prime award documents. Review by the PI of progress reports and invoices from the subrecipient must occur regularly, and the PI must sign their acceptance of all invoices received prior to payment. Invoiced expenses from the subawardee should be reviewed for allowability, reasonableness, and compatibility with the subaward budget prior to signing the invoice and releasing for payment.